FATCA — Information Reporting and Withholding Under Chapter 4 (Portfolio 6565)


Stephen Nauheim

Managing Director

PricewaterhouseCoopers LLP


Nils Cousin

Manager Of International Tax

PricewaterhouseCoopers LLP


Candace Ewell


PricewaterhouseCoopers LLP


Robert Limerick

Managing Director, Global Information Reporting

PricewaterhouseCoopers LLP


Jon Lakritz

Managing Director



Rebecca Lee


PricewaterhouseCoopers LLP

At a glance

I. Introduction and History
II. Rules Applicable to Withholding Agents
III. Rules Applicable to FFIs
IV. Special Considerations for Insurance Companies
V. Special Considerations for Asset Managers
VI. Rules Applicable to NFFEs
VII. Special Considerations for Other Industries and Entities
VIII. Payee Identification Procedures
IX. Intergovernmental Agreements
X. Liability for Withheld Tax and Refund Procedures
XI. Other FATCA Provisions


These requirements generally require: (i) non-U.S. financial institutions to enter into agreements with the Internal Revenue Service under which they agree to identify and report U.S. account holders, and (ii) non-U.S. nonfinancial entities to disclose direct and indirect U.S. owners in certain circumstances, and which imposes a 30% withholding tax on certain payments to non-U.S. financial institutions and nonfinancial entities that do not comply with chapter 4's requirements. This Bloomberg Tax Portfolio, FATCA — Information Reporting and Withholding Under Chapter 4 covers the chapter 4 withholding and reporting mechanism; the definitions and requirements chapter 4 places on both foreign financial institutions and nonfinancial entities (including rules under which entities with certain characteristics may qualify for exemption from some or all of chapter 4's requirements); due diligence and reporting; refund procedures; the impact of intergovernmental exchange of information agreements; and specific issues affecting certain industries, such as asset management and insurance.

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